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Barker Poland Asset Management LLP (“we”) and members of our group are committed to keeping your personal data safe and to ensuring the integrity and security of any personal data we may process. We welcome the introduction of the new European legislation including the General Data Protection Regulation (“GDPR”) which came into force on 25th May 2018, and applicable national acts implementing the GDPR such as the UK Data Protection Act 2018 (or such other UK laws implementing the GDPR in the UK), with the objective of establishing greater protection of personal data and enhancing your rights in respect of your personal data.
We ask you to read this privacy statement very carefully as it contains important information on the way in which we will process your personal data, in particular:
What is personal data and how is it collected?
Personal data includes any information that directly or indirectly identifies an individual. We collect personal data relating to you and your use of our services from a variety of sources, which are detailed below.
We may collect certain personal data, such as personally identifiable information (such as name, date of birth), contact information (such as telephone number, address, email), financial information, employment and education data, information about your health (see below), other information gained during interactions or correspondence with you and, with your explicit consent, sensitive personal data (such as physical or mental health conditions).
We may collect your personal data directly from you, as well as from other parties. This includes personal data where you apply for a joint product or service (e.g. joint accounts) or where you agree to act as a Third Party Authority for a client of ours, as well as from third parties, such as credit reference agencies, fraud prevention agencies, electoral roll, financial advisors, court records of debt judgments and introducers and other publicly available sources.
Our legal basis for processing your personal data
We will only process your data where we have a legal basis for doing so. We may rely on the following legal bases for collecting and further processing your personal data:
Why we process personal data?
We will process your personal data for the following purposes:
We are required to gain your explicit consent prior to processing any sensitive information about you, for example information about your physical health.
We may use your personal data for our legitimate business interests in order to allow us to provide the best services and customer experience and to ensure our service remains relevant and tailored to your needs. For example, we may rely on our legitimate interest to process your personal data for the following purposes:
Please note you have the right to object to any processing for which we rely on legitimate interest as the legal basis. You can do so by using the contact details set out at the end of this privacy statement.
Who we share your personal data with?
We share your data with approved third-party providers that have adequate data protection measures in place that align with the requirements of the data protection regulation. For example:
Your data may be shared with organisations outside of the United Kingdom that are subject to appropriate data protection legislation and have adequate data protection safeguards. We do not sell your personal data or other information to any third party.
Your rights in respect of your data are:
Personal data provided in respect of third parties
You acknowledge that you must have the authority to provide any third party’s personal data to us and agree to share this data protection statement with such third parties and inform them of the details you have advised us of.
Our retention policy
We will regularly review our records to ensure that we do not retain your personal data longer than is necessary, unless there is a legal reason for extended retention.
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Review of this policy
We may make changes to this policy from time to time and will post such updates on our website.
Who are we and how to contact us?
Barker Poland Asset Management LLP is a data controller for the purposes specified in this privacy statement. You can contact us directly if you have any questions about this privacy statement or in order to exercise your data subject rights by addressing your email questions and requests to firstname.lastname@example.org or by using the below details.
Barker Poland Asset Management LLP
128 Queen Victoria Street
Tel: 020 3100 8308
 Process and processing have very wide meanings under the GDPR. They mean any operation (or set of operations) performed on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
 Sensitive personal data is personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
 A data controller determines the purposes and means of processing personal data.